In a much-anticipated decision, the United States Court of Appeals for the Third Circuit recently held that unsecured noteholders’ claims against a debtor for certain “Applicable Premiums” were the “economic equivalent” to...more
When it rains, it pours. On January 23, 2023, the New York Department of Financial Services announced that it had issued certain Guidance on Custodial Structures for Customer Protection in the Event of Insolvency in which it...more
3/1/2023
/ Crypto Exchanges ,
Cryptoassets ,
Custody Rule ,
Investment ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
NYDFS ,
Private Equity Funds ,
Proposed Amendments ,
Rulemaking Process ,
Securities and Exchange Commission (SEC)
Demand for virtual currency services, including custody services, has soared in the past several years. Like their counterparts in traditional finance, these custodians are stewards of retail and institutional customer funds...more